Lance Wallach National Society of Accountants Speaker of The Year

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  1. 412i IRS audits, listed transactions
    ________________________________________
    April 24, 2012 By Lance Wallach, CLU, CHFC
    ________________________________________

    IRS auditing 412i plans
    Protecting Clients From Fraud, Incompetence, and Scams
    By: Lance Wallach
    Published by John Wiley and Sons, Inc.
    Copyright Ó 2010. All rights reserved.

    Excerpts have been taken from this book about:

    Bruce Hink, who has given me permission to utilize his name and circumstances, is a perfect example of what the IRS is doing to unsuspecting business owners. What follows is a story about Bruce Hink and how the IRS fined him $200,000 a year for being in what they called a “listed transaction”. In addition, I believe that the accountant who signed the tax return and the insurance agent who sold the retirement plan will each be fined $200,000 as material advisors. We have received a large number of calls for help from accountants, business owners, and insurance agents in similar situations. Don’t think this will happen to you. It is happening to a lot of accountants and business owners, because most of these so-called listed, abusive plans, or plans substantially similar to the so-called listed, are currently being sold by most insurance and without an agent.

    I took six months of making calls to the insurance company to get a new insurance agent assigned. By then, the IRS had started an examination of the pension plan. Bruce asked for advice from the CPA and the local attorney (who had no previous experience in such cases), which made matters worse, with a “big name” law firm being recommended and more than $30,000 ways approached by many people who have questions about tax reduction plans that they have heard about.

    I have been an expert witness in many of these 419 and 412(i) lawsuits and I have not lost one of them. If you sold one or more of these plans, get someone who really knows what they are doing to help you immediately. Many advisors will take your money and claim to be able to help you. Make sure they have experience helping accountants who signed the tax returns. IRS calls them material advisors and fines them $200,000 if they are incorporated or $100,000 if they are not. Do not let them learn on the job, with your career and money at stake.




    Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, abusive tax shelters, financial, international tax, and estate planning. He writes about 412(i), 419, Section79, FBAR and captive insurance plans. He speaks at more than ten conventions annually, writes for more than 50 publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Public Radio’s “All Things Considered” and others. Lance has written numerous books including “Protecting Clients from Fraud, Incompetence and Scams,” published by John Wiley and Sons, Bisk Education’s “CPA’s Guide to Life Insurance and Federal Estate and Gift Taxation,” as well as the AICPA best-selling books, including “Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots.” He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxadvisorexpert.com.
    The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.

    ReplyDelete
    Replies
    1. As an expert witness, Lance Wallach has never lost a case. Lance Wallach has also written "CPA's guide to life insurance".
      http://lancewallachchfc.blogspot.com/
      https://www.youtube.com/watch?v=WTMWg6bn0Bc
      http://www.section79plan.org/
      http://419plans.blogspot.com/2014/03/fbarovdi-lance-wallach-fbar-offshore.html?showComment=1397481910879#c7820180386593901962
      click the links for more information
      or google Lance Wallach- Lance Wallach Expert Witness- Lance Wallach CPA's Guide to Life Insurance- Lance Wallach As and Expert Witness-

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    2. .
      Reporting by U.S. Persons Holding Foreign Financia
      Contact Information
      Email :
      LanWalla@aol.com
      Phone :
      516-983-5007
      Address :
      Lance Wallach
      www.taxaudit419.com
      www.vebaplan.org
      IRS Form 8938
      FATCA requires any U.S. person holding foreign financial assets with an aggregate value exceeding $50,000 to report certain information about those assets on a new form (Form 8938) that must be attached to the taxpayers annual tax return. Reporting applies for assets held in taxable years beginning on or after January 1, 2011. Failure to report foreign financial assets on Form 8938 will result in a penalty of $10,000 (and a penalty up to $50,000 for continued failure after IRS notification). Further, underpayments of tax attributable to non-disclosed foreign financial assets will be subject to an additional substantial understatement penalty of 40 percent.
      Under FATCA, U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS on a new form attached to their tax return. Penalties apply for failure to comply with this new reporting requirement.

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    3. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205 .

      Delete
    4. As an expert witness, Lance Wallach has never lost a case. Lance Wallach has also written "CPA's guide to life insurance".
      http://lancewallachchfc.blogspot.com/
      https://www.youtube.com/watch?v=WTMWg6bn0Bc
      http://www.section79plan.org/
      http://419plans.blogspot.com/2014/03/fbarovdi-lance-wallach-fbar-offshore.html?showComment=1397481910879#c7820180386593901962
      click the links for more information
      or google Lance Wallach- Lance Wallach Expert Witness- Lance Wallach CPA's Guide to Life Insurance- Lance Wallach As and Expert W

      Delete
    5. As an expert witness, Lance Wallach has never lost a case. Lance Wallach has also written "CPA's guide to life insurance".
      http://lancewallachchfc.blogspot.com/
      https://www.youtube.com/watch?v=WTMWg6bn0Bc
      http://www.section79plan.org/
      http://419plans.blogspot.com/2014/03/fbarovdi-lance-wallach-fbar-offshore.html?showComment=1397481910879#c7820180386593901962
      click the links for more information
      or google Lance Wallach- Lance Wallach Expert Witness- Lance Wallach CPA's Guide to Life Insurance- Lance Wallach As and Expert W

      Delete
  2. Captive Insurance & 419 Plans Litigation
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,Captive Insurance,Captive Insurance Lawsuits,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,

    THURSDAY, FEBRUARY 27, 2014
    419, 412i, Captive And Section 79 Plans Continue To Draw IRS Attention.
    BY LANCE WALLACH, CONSULTANT & EXPERT WITNESS

    Recent court cases have highlighted serious problems in welfare benefit plans issued by Nova Benefit Plans. Recently unsealed IRS criminal case information now raises concerns with other plans as well. If you have any type plan issued by NOVA Benefit Plans, U.S. Benefits Group, Benefit Plan Advisors, Grist Mill trusts, Rex Insurance Service or Benistar, you may have a criminal problem. You may be subject to an audit or in some cases, criminal prosecution.

    On November 17th, Fifty-nine pages of search warrant materials were unsealed in the Nova Benefit Plans litigation currently pending in the U.S. District Court for the District of Connecticut. According to these documents, the IRS believes that Nova is involved in a significant criminal conspiracy involving the crimes of Conspiracy to Impede the IRS and Assisting in the Preparation of False Income Tax Returns.

    In 2010, seventy armed IRS Criminal Division special agents raided the offices of Nova Benefit Plans. The IRS has taken other recent criminal enforcement actions in other states including Nebraska and Milwaukee, Wisconsin. The IRS has told the court that it believes Nova is promoting abusive "section 419" welfare benefit plans.

    The IRS claims that a cooperating witness and several undercover agents "penetrated" Nova to ascertain its internal operations. They say Nova helped their clients violate tax laws by claiming the most minor injuries as permanent disabilities to qualify for special tax treatment. In other words, they would assist clients claim a minor scrape was a disabling and disfiguring permanent injury.

    The IRS also claims that Nova assisted clients in backdating documents filed with the IRS.

    According to the IRS, Nova's plan was a scam because Nova helped taxpayers claim false disabilities. The Internal Revenue Code says disability payments are tax free if there is a permanent loss of a bodily part or function. A small scrape is a far cry from the loss of an eye."

    ReplyDelete
    Replies
    1. 412i 419E IRS Audits and Problems
      412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
      Tuesday, November 27, 2012

      CJA & Associates and 412i, 419, and Other Abusive Plans



      For help with CJA & Associates and 412i, 419, and other abusive plans contact Lance Wallach at lawallach@aol.com or call 516-938-5007. Lance Wallach is the leading expert on 412i, 419, Section 79 and Captive Insurance Plans. Lance has helped hundreds of people resolve their problems and get all their money back, usually without a lawsuit. Google Lance Wallach and see why CJA & Associates, insurance companies, and the IRS do not want to fight with Lance Wallach.

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    2. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205 .

      Delete
  3. Help with Common IRS Problems

    Monday, February 17, 2014

    419 Insurance Welfare Benefit Plans Get Accountants Into Trouble
    419 Insurance Welfare Benefit Plans Get Accountants Into Trouble



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    1. As an expert witness, Lance Wallach has never lost a case. Lance Wallach has also written "CPA's guide to life insurance".
      Tax Expert, Author, Expert Witness, Speaker Lance Wallach discussing tax audits, penalties, abusive tax shelters, 412i plans, 419e plans, 6707A plans, insurance fraud, listed transactions, etc. at convention. Contact him at 516-236-8440 for tax advice, audit defense.
      http://lancewallachchfc.blogspot.com/
      https://www.youtube.com/watch?v=WTMWg6bn0Bc
      http://www.section79plan.org/
      http://419plans.blogspot.com/2014/03/fbarovdi-lance-wallach-fbar-offshore.html?showComment=1397481910879#c7820180386593901962
      click the links for more information
      or google Lance Wallach- Lance Wallach Expert Witness- Lance Wallach CPA's Guide to Life Insurance- Lance Wallach As and Expert Witness- Lance Wallach 419- Lance Wallach abusive tax shelters-

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    2. robin weingast 419 audit google lance wallach for more
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      robin weingast 419 audit google lance wallach for more Summary
      robin weingast 419 audit google lance wallach for more received their first complaint on 12/19/2012.
      Information about robin weingast 419 audit google lance wallach for more was first submitted to Scambook on Dec 19, 2012.

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    3. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205 .

      Delete
  4. Captive Insurance & 419 Plans Litigation

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    Feb 27, 2014 - By Lance Wallach, Consultant & Expert Witness. Recent court cases have highlighted serious problems in welfare benefit plans issued by Nova ...
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    1. 412i Plans
      Such plans can be abusive with cash value life insurance. For more information visit www.taxlibrary.com or www.experttaxadvisors.org.
      Captive Insurance Plans
      These were listed transactions and then taken off the list. IRS still looks closely at them. They are usually sold by life insurance agents.
      Section 79 plans
      IRS is looking very closely at section 79 plans. They are usually sold by life insurance agents.
      Hiding Income Offshore
      The IRS aggressively pursues taxpayers and promoters involved in abusive offshore transactions. Taxpayers have tried to avoid or evade U.S. income tax by hiding income in offshore banks, brokerage accounts or through other entities. Recently, the IRS provided guidance to auditors on how to deal with those hiding income offshore in undisclosed accounts. The IRS draws a clear line between taxpayers with offshore accounts who voluntarily come forward and those who fail to come forward.
      Taxpayers also evade taxes by using offshore debit cards, credit cards, wire transfers, foreign trusts, employee-leasing schemes, private annuities or life insurance plans. The IRS has also identified abusive offshore schemes including those that involve use of electronic funds transfer and payment systems, offshore business merchant accounts and private banking relationships.
      Filing False or Misleading Forms
      The IRS is seeing scam artists file false or misleading returns to claim refunds that they are not entitled to. Frivolous information returns, such as Form 1099-Original Issue Discount (OID), claiming false withholding credits are used to legitimize erroneous refund claims. The new scam has evolved from an earlier phony argument that a “strawman” bank account has been created for each citizen. Under this scheme, taxpayers fabricate an information return, arguing they used their “strawman” acco

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    2. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205 .

      Delete
  5. Money talks, and it says, 'Penny-pincher' - Newsday
    www.newsday.com › Lifestyle‎
    Newsday
    Sep 5, 2013 - Lance Wallach is a 'Vette vet who has a lot of drive. (Credit: Handout). Until I was in fifth grade we lived in Queensbridge, a low-income housing ...
    You've visited this page 2 times. Last visit: 3/12/14
    Lance Wallach | Business Valuations.org
    business-valuations.org/tag/lance-wallach/‎
    Feb 24, 2014 - America's Best-selling CPE Programs New BISK CPEasy™ CPE Self-Study Course Author/Moderator: Lance Wallach, CLU, CHFC, CIMC ...
    As an expert witness Lance Wallach side has never lost a case
    expertwitnesslancewallch.blogspot.com/‎
    Jan 7, 2014 - Share to TwitterShare to FacebookShare to Pinterest. Labels: lance wallach expert witness, sea Nine, VEBA. United States Of America, Oct. 9th ...
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    [PDF]
    Defined Contribution Health Plans: Let the Buyer Beware Opinion by ...
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    Defined Contribution Health Plans: Let the Buyer Beware. Opinion by Lance Wallach, CLU, ChFC, CIMC and Ronald H. Snyder, JD, MAAA, EA. Health care ...
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  6. Captive Insurance & 419 Plans Litigation
    lancewallachchfc.blogspot.com/‎
    Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on ...
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    Lance Wallach - The Nation's Foremost 419 and 412i plans expert
    www.lancewallach.com/‎
    Lance Wallach is the nation's foremost expert on 419 plans,412i plans,listed transactions,reportable transactions,Section 79 plans, captive insurance plans, ...
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    Lance Wallach | LinkedIn
    www.linkedin.com/in/lancewallach‎
    Greater New York City Area - ‎director at taxaudit419.com
    View Lance Wallach's professional profile on LinkedIn. LinkedIn is the world's largest business network, helping professionals like Lance Wallach discover ...
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    Lance Wallach (LanceWallach) on Twitter
    https://twitter.com/LanceWallach‎
    The latest from Lance Wallach (@LanceWallach). Defending businesses & financial professionals from IRS audits, insurance & brokerage firms. 419 & 412 Plan ...
    Lance Wallach shared this on Google+
    FBAR/OVDI LANCE WALLACH
    multinationaltaxesfbarovdi.blogspot.com/‎
    Mar 4, 2014 - June 30 2014 is the annual deadline for U.S. taxpayers, (including resident aliens) to timely reports of foreign financial accounts for year ending ...
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    https://www.facebook.com/lance.wallach‎

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  7. Tax Expert Lance Wallach Speaking at Attorney CPA Convention ...
    ► 7:55► 7:55
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    Dailymotion
    Mar 2, 2010
    Tax Expert, Author, Expert Witness, Speaker Lance Wallach discussing tax audits, ... Defend Against IRS Penalties, Audits, Tax Shelters, Plans ...
    412i-419 Plans: 412i-419 Plans: IRS tax relief firm, Lance Wallach ...
    419plans.blogspot.com/2014/03/412i-419-plans-irs-tax-relief-firm.html‎
    Mar 12, 2014 - FBAR/OVDI LANCE WALLACH FBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank ...
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    IRS tax relief firm, Lance Wallach, speaking - 412i-419 Plans - Blogger
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    Mar 12, 2014 - How to Avoid IRS Fines for You and Your Clients | LifeHealthPro Lance Wallach National Society of Accountants Speaker of ... taxshelterp.
    IRS tax relief firm, Lance Wallach, speaking - 412i-419 Plans - Blogger
    419plans.blogspot.com/2014/03/irs-tax-relief-firm-lance-wallach.html‎
    Mar 11, 2014 - For help with CJA & Associates and 412i, 419, and other abusive plans contact Lance Wallach at lawallach@aol.com or call 516-938-5007.
    IRS tax relief firm, Lance Wallach, speaking - 412i-419 Plans - Blogger
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    Mar 11, 2014 - Participated in a Sea Nine VEBA plan_Contact Lance Wallach: IRS to Audit Sea Nine VEBA Participating Employers... : By Lance Wallach,.
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    WeFiveKings: Calling Out Lance Wallach
    wefivekingsblog.blogspot.com/2010/11/calling-out-lance-wallach.html‎
    Nov 16, 2010 - Consider, for example, this article by Lance Wallach titled "The dangers ... "In recent years, the Internal Revenue Service has identified many of ...
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  8. 6707A Penalties & 419 Plans Litigation
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.Benistar,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,6707a Penalties,6707a lawsuits,6707a problems

    Published Articles on VEBA Plans by Lance Wallach:

    Monday, March 24, 2014

    IRS Circular 230

    Appeals officers, revenue officers, Counsel or similar officers or employees of the Internal Revenue Service or the Treasury Department.
    A registered tax return preparer’s authorization to practice under this part also does not include the authority to provide tax advice to a client or another person except as necessary to prepare a tax return, claim for refund, or other document intended to be submitted to the Internal Revenue Service.
    (4) An individual who practices before the Internal Revenue Service pursuant to paragraph (f)(1) of this section is subject to the provisions of this part in the same manner as attorneys, certified public accountants, enrolled agents, enrolled retirement plan agents, and enrolled actuaries.
    (g) Others. Any individual qualifying under paragraph §10.5(d) or §10.7 is eligible to practice before the Internal Revenue Service to the extent provided in those sections.
    (h) Government officers and employees, and others. An individual, who is an officer or employee of the executive, legislative, or judicial branch of the United States Government; an officer or employee of the District of Columbia; a Member of Congress; or

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  9. sBlogsBuyers GuideBenefits Selling MagazineWebcastseNewslettersResource CenterEventsVideoBenefits BrokersBenefits ManagersRetirement AdvisorsFreeERISA

    Lance Wallach
    How to get fined $100,000 by the IRS and lose your license
    By LANCE WALLACH | December 17, 2008
    Over the past decade, business owners have been overwhelmed by a plethora of arrangements designed to reduce the cost of providing employee benefits and taxes, while simultaneously increasing their own retirement savings. The solutions ranged from

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  10. Veba Health Care

    SUNDAY, DECEMBER 1, 2013
    IRS to Audit Sea Nine VEBA Participating Employers. Lance Wallach, expert witness.
    The IRS may be auditing many more participating employers in the coming months.

    In recent months, I have received phone calls from participants in the Sea Nine VEBA and have learned that the IRS may be auditing many more participating employers in the coming months. To better assist current Sea Nine clients and those that are now or may be under audit in the future, my associates who are CPAs, tax attys and former IRS employees will continue to help with the Sea Nine VEBA victims and others in 419 412i captive insurance and section 79 scams and answer the following:

    • What is the IRS’s position with respect to the Sea Nine VEBA,419 captive insurance and section 79 scams?

    • What will be the likely result of my audit?

    • What if I don't agree with my audit results?

    • What are other participants doing with respect to the audits?

    • Will the IRS impose interest and penalties?

    • What is a “listed transaction” ?

    ReplyDelete
    Replies
    1. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205 .

      Delete
  11. Had tax problems Lance Wallach fixed
    by Robbendo Sep 04, 2012 22 comments Review #: 343358
    ← Previous 4 of 4 Lance Wallach Reviews
    Company Lance Wallach
    Location New York City, New York
    Category Tax services
    Views 103

    I had some troubles with listed transactions.

    It was a few years ago. And I was sold some different products that were horrible because I was hit with abusive transactions through the IRS and was facing some stiff penalties.

    Enter LANCE WALLACH. I contacted him after seeing his information posted on the internet. I didn't know if I could trust what he promised but I was facing such heavy fines, it seemed I needed to try.

    Thank goodness for Lance Wallach. Will maybe write more at another time, but for now, just a thanks to Lance for getting me out of some really bad situations.

    ReplyDelete
  12. Captive Insurance & 419 Plans Litigation
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,Captive Insurance,Captive Insurance Lawsuits,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,

    WEDNESDAY, JANUARY 8, 2014
    Captive Insurance
    Choosing a domicile.
    ■ Regulatory environment. Some jurisdictions are friendlier than others, or their
    statutes may permit different used and forms of captives.
    ■ Minimum capitalization requirements – varies between jurisdictions from
    $150,000 to $750,000. Separate series of a group captive requires risk-based
    amount of capital, typically
    ■ Start-up costs and annual maintenance – typical start-up costs range from
    $50,000 to $80,000 for pure captive (plus required capital) and from $20,000
    to $25,000 for cell (or series) of group captive.
    ■ Underwriting risk classification
    • Traditional coverage or non-traditional coverage, such as loss of license.
    ■ Tax implications.
    • Small insurance company with premiums less than $1,200,000. See
    Section 831(b) of the Internal Revenue Code. Applies to US tax-law
    compliant companies.
    • Excise taxes on premiums paid for non-US captives.

    Posted by Lance Wallach at 8:31 AM 13 comments:
    Labels: Captive Insurance, Captive Insurance History, compliance, Lance Wallach, lance wallach expert witness
    Newer Posts Older Posts Home
    Subscribe to: Posts (Atom)
    LANCE WALLACH IS A NATIONALLY RECOGNIZED EXPERT, AUTHOR, AICPA INSTRUCTOR AND SPEAKER.
    "Protecting Clients from Fraud, Incompetence, and Scams" published by John Wiley & Sons
    Mr. Wallach is the National Society of Accountant's Speaker of the Year and the author of numerous professional books, including:
    "Avoiding Circular 230 Malpractice Traps and Common Abusive Small Businesss Hot Spots" by the AICPA - author/moderator Lance Wallach
    The AICPA's "The team approach to Tax, Financial and Estate Planning."
    "The CPA's Guide to Life Insurance" by Bisk CPEasy
    "Wealth Preservation Planning" by the National Society of Accountants
    "The CPA's Guide to Federal and Estate Gift Taxation" publis

    ReplyDelete
    Replies
    1. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205 .

      Delete
  13. 412i-419 Plans
    419 & 412i benefit plan,abusive tax shelters, Lance Wallach Expert Witness

    Wednesday, March 12, 2014
    FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att...
    FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att...: FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS





    Lance Wallach shared this on Google+

    Amazon.com: Lance Wallach: Books, Biography, Blog, Audiobooks ...
    www.amazon.com/Lance-Wallach/e/B002PCF57E‎
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    Visit Amazon.com's Lance Wallach Page and shop for all Lance Wallach books and other Lance Wallach related products (DVD, CDs, Apparel). Check out ...

    Captive Insurance & 419 Plans Litigation
    lancewallachchfc.blogspot.com/‎
    Feb 27, 2014 - By Lance Wallach, Consultant & Expert Witness. Recent court cases have highlighted serious problems in welfare benefit plans issued by Nova ...
    Lance Wallach shared this on Google+

    Posted by lance wallach at 3:23 PM
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    ReplyDelete
  14. APRllachApril 28, 2014 at 4:34 AM
    T a x L i b r a r y . U S
    5 1 6 - 9 3 8 - 5 0 0 7
    Nationwide Assistance Bookmark and Share
    WallachInc@gmail.com
    The "Tax Resolution Services" of
    Lance Wallach
    The Leading Authority on 412i / "419 Plans"
    and IRS "Tax Shelter" Issues

    When you have problems with the IRS, you need a proven winner to stand up to the IRS to help you avoid large"IRS penalties and interest" that could put you out of business.

    If you are suffering from "tax problems" regarding "welfare benefit plan audits" and need 412i and "419 plan help", assistance with captive insurance, Section 79 plans, listed or reportable transactions, or IRC 6707A, you need
    Lance Wallach's "expert witness testimony" on your side.
    Lance Wallach's side has NEVER lost a case.

    ReplyDelete

    Lance WallachApril 28, 2014 at 9:12 AM
    412i-419 Plans
    419 & 412i benefit plan,abusive tax shelters, Lance Wallach Expert Witness

    Friday, March 28, 2014
    Captive Insurance & 419 Plans Litigation: February 2013
    Captive Insurance & 419 Plans Litigation: February 2013

    ReplyDelete
    Replies
    1. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205 .

      Delete
  15. Veba Health Care

    MONDAY, JUNE 24, 2013
    Examination Guidelines - Organizational Requirements
    4.76.18.3.1.1 (06-21-2002)

    1. Review the trust agreement, or other organizational document, and obtain answers to the following questions:
    A. Is the VEBA a separate legal entity?
    B. What provision is made for the distribution of remaining assets upon termination of the VEBA?
    C. Who controls the VEBA?
    D. What is the employment related common bond?
    E. What are the eligibility requirements?
    F. What benefits are provided?
    2. Review the summary plan description for consistency with the plan document as well as any additional limitations on eligibility or benefits.
    4.76.18.3.2 (06-21-2002) Activities
    1. Substantially all of an IRC section 501(c)(9) organization's operations must be in furtherance of providing permissible benefits.
    2. A VEBA may provide some nonqualifying benefits, but it will not qualify for exemption if it systematically and knowingly provides nonqualifying benefits of more than a de minimus amount.
    4.76.18.3.2.1 (06-21-2002) Examination Guidelines - Activities
    1. Review the minute book to obtain a general overview of the VEBA's activities. Note any comments regarding benefits, loans, reimbursements, and other items, which raise questions as to the association's activities.
    2. Interview the trustee and or the plan administrator to identify any changes in the operations of the VEBA since it received exemption. Ask specifically for:
    A. Any amendments to the plan or trust.
    B. Current summary plan description.
    C. Any rulings received subsequent to exemption.
    D. Copies of Forms 5500 filed by the employer.

    ReplyDelete
  16. n Page
    Quick Search
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    Bio Link
    Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive insurance plans. He speaks at more than ten conventions annually, writes for more than 20 publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Public Radio's All Things Considered, and others. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation, as well as AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and his side has never lost a case. Visit www.Attorneys-USA.org for more on this subject. National Toll Free Number 516-938-5007
    Twitter Link
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    Taxpayer Disclosure

    Posted by 6707a at 4/24/2014 1:52 PM | Add Comment
    Abusive Insurance, Welfare Benefit, and Retirement Plans

    Posted by 6707a at 4/8/2014 12:01 PM | Add Comment
    What is an IRS Tax Audit Appeal?

    ReplyDelete
  17. Our Team Defends Insurance Agents Who Sold 419 and 412i Benefit Plans

    "life insurance expert witnesses" "tax shelter litigation" "investment fraud" "retirement
    insurance expert witnesses" "insurance plan fraud" "life insurance fraud" 'life
    insurance lawsuit help" "retirement plan lawsuit" "insurance expert witness" "expert
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    "expert witness 412i plans" "expert testimony retirement insurance"

    “Grist Mill Trust lawsuit” “Millennium Plan lawsuit” “Sterling Benefit Plan lawsuit”
    “Benistar lawsuit” “SADI Trust lawsuit” “Beta 419 lawsuit” “Bisys lawsuit” “Creative
    Services Group lawsuit” “Compass 419 lawsuit” “Niche 419 lawsuit” “Sea Nine Veba
    lawsuit" Nutmeg, John Hancock

    "lance wallach" “6707A” “captive insurance” “tax shelter fraud” “section 79”"tax
    letter" "irs letter" "irs letters" "irs determination letter" “419 plan help” 412i 6707a "form

    ReplyDelete
    Replies
    1. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205 .

      Delete
  18. The Home of Business Appraisals
    Your Valuation Consultants
    Valuation Services
    Contact
    BV Company Blog
    Better Business Valuation: separating teachers & students


    ‘We wrote the books on how to value a business that other valuation companies live by! If you want to sleep soundly at night, don’t go to the students for your financial solutions, seek the teachers!’

    -Lance Wallach



    business valuations
    The Business of Business
    Valuations…
    We cater to US-based, privately-held businesses that need an independent valuation, or third-party company appraisal services. Company valuation resources are available to you, courtesy of the age of information. Anybody could value their own business. We’re trained financial analysts and lawyers who’ve studied economic trends with the best of them. Our fair service, pricing, attention to detail, expert staff, valuation methods, and customer-focused approach make our business valuation services ultimately worth your time.

    Nationwide Business
    Valuations
    NSAS speaker of the year and AICPA faculty Lance Wallach is a valuations analyst. He and his certified, expert team of CPA valuation consultants service private businesses seeking appraisals or litigation support. Their valuation formula caters to nationwide business sales or purchases with revenues of $1MM to 55MM, and small business revenues from $500k to $5MM. Lance Wallach’s and his CPA consultants’ confidence is predicated on their extensive financial analyst experience in New York and the U.S. Nationwide.

    Business Appraisal Services: Our
    Specialties
    You can benefit from our valuation services if you are: a firm facing Merger & Acquisition decisions; if you are an owner who needs CFO business advisory for team-members; if you are an attorney, business owner, or accountant who needs an expert to perform forensic valuation services, like fraud & litigation support. Other services include valuation buy/sell agreements, partnership dissolution, marital dissolution of business assets, and estate, gift or tax matters.


    Your Next Step: Company Valuation Free
    Consultation
    If you have questions and would like a free consultation, please call 516-938-5007 to speak with an expert business valuator

    You can also email to wallachinc@gmail.com
    Free Add Url Business Directory

    ReplyDelete
  19. Captive Insurance & 419 Plans Litigation: February 2014
    Captive Insurance & 419 Plans Litigation: February 2014



    s Lance Wallach,412i Help ...
    You shared this on Google+
    Investment News - Lance Wallach - 412i and 419 plan litigatation
    www.taxaudit419.com/Article-6-Advisors_Staring_at_Slew_of_Litigatio...‎
    "expert witness testimony in tax shelter lawsuit" “Lance Wallach” “412i ... “life insurance fraud” “life insurance scam” “health insurance scam” health insurance
    Lance Wallach | LinkedIn
    www.linkedin.com/in/lancewallach‎
    Greater New York City Area - ‎director at taxaudit419.com
    View Lance Wallach's professional profile on LinkedIn. ... "CPAs' Guide to Life Insurance", and "Protecting Your Clients From Fraud, Incompetence and Scams," ...
    You shared this on Google+
    Lance Wallach Life Insurance: Life insurance beneficiary files ...
    lancewallachexpertatyourservice.blogspot.com/.../life-insurance-benefici...‎
    by Lance Wallach - in 56 Google+ circles
    Apr 5, 2013 - Life insurance beneficiary files putative class action lawsuit against life insurer targeting unclaimed property practices, Edwards Wildman ...
    You +1'd this
    Lance Wallach's Nationwide Life Insurance Litigation Blog
    www.lifeinsurancelitigation.net/LifeInsuranceNewsBlog.html‎
    Jan 28, 2014 - Lance Wallach's Blog covering topics re: Insurance LitigationAttorneys representing cases, ligitation support, Insurance Expert Witness ...
    Section 79 Plans: Section 79 by Lance Wallach, expert witness.
    lancesvids.blogspot.com/.../section-79-by-lance-wallach-expert_27.html‎
    Feb 27, 2014 - Benistar,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i ... Section 79 by Lance Wallach, expert witness. ... the purchase of an individually owned life insurance policy that th

    ReplyDelete
  20. Lance Wallach Life Insurance

    Tuesday, January 28, 2014
    Why Your Life Insurance Claim Is Denied
    Article 3 of 6 in Life Insurance Claims, Attorneys, and Lawsuits

    If your life insurance claim is denied, you need to find out why and decide what action is available to you. A life insurance claim denial can be difficult, but if handled appropriately you may be able to get the benefits.
    TIP: If your life insurance claim is denied, you should contact an experienced insurance attorney as soon as possible. An attorney can research the claim denial and assist you collecting any benefits wrongfully denied.
    Life Insurance Claims Denied for False Information
    The most common reason a life insurance claim is denied is an alleged material misstatement made by the insured on the application. A material misstatement is one that is stated on the application that if not stated would have clearly led to a refusal by the insurer to issue the policy. Any statement, or omission, that hides the truth about a major health problem which could have influenced the insurance underwriting, the decision to offer a policy, or the cost of insurance is considered a material misstatement or omission. When life insurance claims are denied for material misstatements, the company is rejecting coverage because it was misled at the time insurance was purchased.
    TIP: Denying coverage for a material misstatement can happen after the life insurance contestability period has expired.
    It is not uncommon for insurance companies to look for material misstatements or omissions that will provide them with a reason to deny a life insurance claim. Make sure you are honest on your life insurance application! It is also a good idea to record or get in writing any statements made to you by the agent. Agents may breeze over information or cut corners to advance a sale, and if you filled out an application following an agent's instructions and your life insurance claim was denied accordingly, you need to challenge the company.

    ReplyDelete
  21. Section 79
    Employee owns a Universal Life contract payable to his personal beneficiary. Internal Revenue has set the Maximum Guideline Level Premium allowed by law for specific age and amount. Employee will be taxed on the permanent benefit portion of the contract.
    Employee contributes up to one-half of this maximum amount to the employer, who matches the contribution and remits one check to the insurance company. This process can result in no imputed income to the employee.
    Employee owns the policy and is free to leave the resulting cash values to earn interest or draw them out as needed.
    If employee terminates employment, he can continue the policy by paying additional premiums himself as needed or letting policy run off existing cash values.
    Generally at least ten employees must be covered. Less than ten employee groups may qualify under Section 79 if they fall within an exception to the general rule.
    Employer

    Tax deducts premiums actually contributed on corporate tax return, under "Employee Benefit Programs."
    No Government approval required.
    Minimum record-keeping
    Employee

    Employee has includable income equal to the cost of the permanent benefit provided by the employer, reduced by any amounts paid by the employee.
    If employee contributions are equal to or greater than employer contributions, the net result is no taxable income to the employee on the cost of insurance. Any dividends actually or constructively received are taxed. (Treas. Reg. 1.79-1(d)(1))
    These plans are sold so insuranc

    ReplyDelete
    Replies
    1. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205 .

      Delete
  22. Lance Wallach
    Managing Director
    The Offices of Lance Wallach
    Serving clients
    nationwide

    Call us today:
    516-938-5007

    Email us at:

    LanWalla@aol.com
    Every one of our consulting attorneys, CPAs & ex
    IRS Agents has over 25 years of professional
    experience! We believe that no firm has more
    experienced professionals to assist our clients
    than we do!
    Specializing in the following services:

    "IRS audit appeals"
    U.S. 'Tax Court' cases
    Multinational taxation consulting
    Incorporating your business
    Recovering losses from insurance companies
    & brokerage firms
    "Tax shelter analysis"
    "Pension plan reviews" & evaluations
    "419"& "412i" benefit plan analysis
    "419" & "412i plan" remediation
    Offshore tax shelter issues
    IRS "listed transactions" assistance

    Expert Witness Testimony For:
    * Taxes
    * Insurance & retirement plan cases
    * SSI & Disability Advocates

    ReplyDelete
  23. Captive Insurance & 419 Plans Litigation
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,Captive Insurance,Captive Insurance Lawsuits,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,

    WEDNESDAY, APRIL 30, 2014
    Captive Insurance Arrangements Are on the IRS Radar
    Lance Wallach

    Large or small, captives must be formed for the right reasons, their premiums must be appropriate and their business plans must involve genuine insurance, captive experts say.



    To Read More Click Link
    Posted by Lance Wallach at 9:09 AM No comments:
    Labels: captive, Captive Insurance, captive Insurance plans, Lance Wallach, lance wallach expert witness
    Older Posts Home
    Subscribe to: Posts (Atom)
    LANCE WALLACH IS A NATIONALLY RECOGNIZED EXPERT, AUTHOR, AICPA INSTRUCTOR AND SPEAKER.
    "Protecting Clients from Fraud, Incompetence, and Scams" published by John Wiley & Sons
    Mr. Wallach is the National Society of Accountant's Speaker of the Year and the author of numerous professional books, including:
    "Avoiding Circular 230 Malpractice Traps and Common Abusive Small Businesss Hot Spots" by the AICPA - author/moderator Lance Wallach
    The AICPA's "The team approach to Tax, Financial and Estate Planning."
    "The CPA's Guide to Life Insurance" by Bisk CPEasy
    "Wealth Preservation Planning" by the National Society of Accountants
    "The CPA's Guide to Federal and Estate Gift Taxation" published by B

    ReplyDelete
  24. Lance Wallach Life Insurance

    Wednesday, March 12, 2014
    Life Insurance_The Bottom Line
    Ill health has left your mother unable to care for herself.
    She needs home care to get by.Thankfully she purchased
    a long-term care insurance policy over a decade ago and
    has been faithfully paying the premiums ever since. She
    was determined her children should not suffer the
    burden of paying for her care later in life.
    But the payment from the insurance company never
    arrives.You call the insurance company over and over
    and send them document after document.They deny
    the claim, citing reasons from“the claim is too late,” to
    “you did not fill out the paperwork,” to“you filled out
    the wrong paperwork.”The denials change each time,
    often citing provisions in the policy that do not exist,
    and often contradicting previous denials.Meanwhile,
    the cost of the care has quickly depleted your mother’s
    savings, and now the bills fall to you,the very prospect
    she sought to avoid.
    “[T]he bottom line is that insurance
    companies make money when they
    don’t pay claims…They’ll do
    anything to avoid paying, because if
    they wait long enough,they know
    the policy holders will die.”
    — Mary Beth Senkewicz, former senior
    executive at the National Association of
    Insurance Commissioners (NAIC)
    The case of 77-year-old Mary Rose Derks from
    Montana attracted congressional attention after the New
    York Times highlighted her plight at the hands of
    insurance company Conseco.
    13 Her family was forced to
    sell their small business after Conseco denied the claim
    one way or another for more than four years. Insurance
    companies have long embraced delaying tactics to avoid
    paying claims, but undoubtedly the most shameful use
    of delay tactics has been by insurance companies
    involved in long-term care insurance. According to Mary
    Beth Senkewicz, a former senior executive at the
    National Association of Insurance Commissioners
    (NAIC), “the bottom line is that insurance companies
    make money when they don’t pay claims…They’ll do
    anything to avoid paying, because if they wait long
    enough, they know the policyholders will die.”14
    For you, making an insurance claim is likely to
    happen at a time when you are most vulnerable. Filing a
    claim with your insurance company usually follows an
    upset to everyday life, that could involve a car accident,
    a tree falling on your house, or hospitalization from a
    serious illness. For the insurance company it is business
    as usual. Many insurance companies routinely delay
    claims to try to avoid paying. By delaying as long as
    possible, the insurance company knows many of its
    claimants will eventually give up, or in some cases die.
    Internal documents from Allstate featured an alligator
    and the caption “sit and wait”—a reference to delaying
    claims to increase the likelihood that a claimant would
    give up.

    ReplyDelete

  25. An organization to help those harmed by the IRS
    Home
    ISSUES
    THIS CAN HAPPEN TO YOU.
    More Articles
    Contact Us
    68 Keswick Lane Plainview NY 11803 us 5169385007 vebaplan@gmail.com
    HomeContact UsTHIS CAN HAPPEN TO YOU.More ArticlesISSUES
    IRS Audited plaintiffs' plan & concluded that the plan failed to comply with 412(i)(3) because it was "overfunded".
    The IRS audited plaintiffs’ plan
    and concluded that the plan failed to comply with § 412(i)(3) because it was
    “overfunded.”

    The United States District Court for the Northern District of Texas recently
    issued several important decisions in MDL No. 1983, a multidistrict
    litigation proceeding designed to address claims related to employee
    benefit plans created under § 412(i) and § 419 of the Internal Revenue Code. For
    example, in two similar § 419 cases, the Court reaffirmed its earlier rulings and

    ReplyDelete
  26. Welcome
    516-938-5007
    or
    ​516-236-8440


    Lance Wallach, Google him, has received thousands of calls from people harmed by the IRS. Some deserve to be fined, but many do not. Some have broken the law, but most did not do so intenditly. The IRS has special task forces out to get many groups of people. For example if you tried to deduct insurance in a retirement plan the IRS may be after you. If you had money overseas for any reason the IRS is probably after you, and may put you in jail. If you baught a product from an insurance company, agent, or even accountant or atty. the IRS may fine you a large amount of money: even if you had saw an opinion letter from a law firm saying it was ok. No one is doing anything about this.

    We have formed an organization to try to help those people. Let us try to help YOU. If you can we are looking for help and support. If the IRS has already wiped you out we will try to help you.

    You may have read about how the IRS gives probllems to political organizations. That is nothing compared to the honest hard working people that the IRS will, or has already harmed. Below are just a few published articles which deal with small segments of this problem that many people have, or will have. We do not give out members names, however some of our members like Lance Wallach are not afraid of the IRS.
    read more
    read more
    Get to know the real truth behind your investment and what you can do to defend yourself. Since 2004, the IRS has amended the tax laws regarding these plans and thus has placed aggressive penalties and fines and aggressively auditing people who don’t know the truth. Consult with us today and let us help guide you through this serious situation and lower your financial risk.

    An organization to help those harmed or will be potential harmed by the IRS
    Our Services
    68 Keswick Lane Plainview NY 11803 us 5169385007 vebaplan@gmail.com
    HomeContact UsTHIS CAN HAPPEN TO YOU.More ArticlesISSUES
    What you need to know

    ReplyDelete
  27. Lawyers, Law Firms, Legal InformationFind a Lawyer

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    Section 79, Captive Insurance, IRS Audits and Lawsuits
    By Lance Wallach, CLU, CHFC

    Firm's Profile & ArticlesFirm's Profile & Articles

    Find a Law Firm:
    ► Need a Lawyer? Let Us Help You

    Section 79 and captive insurance plans with life insurance in them are being looked at by the IRS. We have received calls from people that are being audited. - The dangers of being "listed" - A warning for 419, 412i, Sec.79 and captive insurance. Accounting Today: October 25, 2010, By: Lance Wallach

    Taxpayers who previously adopted 419, 412i, captive insurance or Section 79 plans are in big trouble.

    In recent years, the IRS has identified many of these arrangements as abusive devices to funnel tax deductible dollars to shareholders and classified these arrangements as "listed transactions."

    These plans were sold by insurance agents, financial planners, accountants and attorneys seeking large life insurance commissions. In general, taxpayers who engage in a "listed transaction" must report such transaction to the IRS on Form 8886 every year that they "participate" in the transaction, and you do not necessarily have to make a contribution or claim a tax deduction to participate. Section 6707A of the Code imposes severe penalties ($200,000 for a business and $100,000 for an individual) for failure to file Form 8886 with respect to a listed transaction.

    But you are also in trouble if you file incorrectly.

    I have received numerous phone calls from business owners who filed and still got fined. Not only do you have to file Form 8886, but it has to be prepared correctly. I only know of two people in the United States who have filed these forms properly for clients. They tell me that was after hundreds of hours of research and over fifty phones calls to various IRS personnel.

    The filing instructions for Form 8886 presume a timely filing. Most people file late and follow the directions for currently preparing the forms. Then the IRS fines the business owner. The tax court does not have jurisdiction to abate or lower such penalties imposed by the IRS.

    Many business owners adopted 412i, 419, captive insurance and Section 79 plans based upon representations provided by insurance professionals that the plans were legitimate

    ReplyDelete
    Replies
    1. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205 .

      Delete
  28. THOUGHTS ON “IRS TAX SHELTERS & 419 PLANS LITIGATION”

    Lance Wallach Your comment is awaiting moderation.
    May 16, 2014 at 8:40 am
    The Offices of Lance Wallach
    Serving clients
    nationwide

    Call us today:
    516-938-5007

    Email us at:

    LanWalla@aol.com
    Every one of our consulting attorneys, CPAs & ex
    IRS Agents has over 25 years of professional
    experience! We believe that no firm has more
    experienced professionals to assist our clients
    than we do!
    Specializing in the following services:

    “IRS audit appeals”
    U.S. ‘Tax Court’ cases
    Multinational taxation consulting
    Incorporating your business
    Recovering losses from insurance companies
    & brokerage firms
    “Tax shelter analysis”
    “Pension plan reviews” & evaluations
    “419″& “412i” benefit plan analysis
    “419″ & “412i plan” remediation
    Offshore tax shelter issues
    IRS “listed transactions” assistance

    Expert Witness Testimony For:
    * Taxes
    * Insurance & retirement plan cases
    * SSI & Disability Advocates

    Our consulting
    attorneys,
    CPAs & ex IRS

    ReplyDelete
  29. 412I, 419E PLANS LITIGATI
    WEDNESDAY

    419PLANS.COM
    419PLANS.COM
    POSTED BY LANCE WALLACH AT 11:52 AM NO COMMENTS:
    MONDAY

    IRS 419 plans
    April 2011 Edition

    By Lance Wallach

    The IRS started auditing § 419 plans in the 1990s, and then continued going after § 412(i) and other plans that they considered abusive, listed, or reportable transactions, or substantially similar to such transactions. If an IRS audit disallows the § 419 plan or the § 412(i) plan, not only does the taxpayer lose the deduction and pay interest and penalties, but then the IRS comes back under IRC 6707A and imposes large fines for not p

    ReplyDelete
  30. 412i 419 sect 79 lawsuits audits www.lancewallach.com for help (plainview)


    © craigslist - Map data © OpenStreetMap
    (google map) (yahoo map)

    compensation: no pay
    Lance Wallach helps with 419 problems. 412i 419 abusive tax shelters IRS audits, lawsuits, Lance Wallach will help www.vebaplan.com
    419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this.
    Dennis Cunning Steve Toth Randall Smith Paul Kaplan Herb Green Casey Hermansen
    Larry Bell Scott Ridge Judy Carsrud Jeffrey Glasberg Herb McDowel
    Greg Roper Joseph Donnelly
    Norm Bevan Michael Sonnenberg
    r Anthony Fakouri
    Steve Burgess
    Robin Weingast
    IRS audits 419 412i captive insurance and section 79 plans. Lance Wallach will help you.

    IRS audits section 79 419 412i plans. www.lancewallach.com for help
    Benistar, IRS raids, Niche, Robin Weingast, Lance Wallach helps, Sadi trust, grist Mill trust, nova 419 welfare benefit plan problems and how Lance Wallach helps.www.vebaplan.com for more help. Sea Nine VEBA, 419, 412i, IRS audits,Sea Nine VEBA, are all audited by the IRS and people in them probably need help.
    Sea Nine VEBA, 419,412i are all IRS audit targets. Lance Wallach can help, www.tazaudit419.com
    419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this. Author to write about these problems.
    Dennis Cunning Steve Toth Randall Smith Paul Kaplan Herb Green Casey Hermansen
    Larry Bell Scott Ridge Judy Carsrud Jeffrey Glasberg Herb McDowel
    Greg Roper Joseph Donnelly
    Norm Bevan Michael Sonnenberg
    Anthony Fakouri
    Steve Burgess
    Robin Weingast
    " Lance Wallach will help fix the problems that people have that are or were in the plans.
    "Professional Benefits Trust" PBI

    "Sea Nine Veba"
    Bisys
    The "Beta Plan"
    The "Millennium Plan"

    Niche
    The "Ridge Plan"


    The "Compass Welfare Benefit Plan"
    "Section 79 Plans"
    "Captive Insurance"
    and other similar "412i retirement plans" and "419 welfare benefit plans

    Lance Wallach, www.taxaudit419.com will help you with these problems and more like section 79, captive insurance lawsuits and IRS audits. People in the section 79 plans 419 welfare benefit plans captive insurance and 412i pension plans are getting audited by the IRS and then they sue. Google Lance Wallach for help with this. If you need help Lance Wallach as an expert witness has never lost a case. You need help NOW.

    Customers of James Cunningham d/b/a Cunningham Financial or CFG Consulting LLC? We want to speak with you!
    IRS audits and lawsuits result from 419 412i captive insurance and section 79 plans. As an expert witness Lance Wallach has never lost a case.
    do NOT contact me with unsolicited services or offers

    ReplyDelete
  31. GoArticles.com Logo
    Search by Author, Title or Content
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    Home Submit Articles Author Guidelines Publisher Guidelines Content Feeds RSS Feeds FAQ Contact Us

    IRS to Audit Sea Nine VEBA Participating Employers by Lance Wallach
    in Finance / Taxes (submitted 2012-10-26)



    In recent months, I have received phone calls from participants in the Sea Nine VEBA and have learned that the IRS may be auditing many more participating employers in the coming months. To better assist current Sea Nine clients and those that are now or may be under audit in the future, my associates who are CPAs, tax attorneys and former IRS employees will continue to help with the Sea Nine VEBA victims and others in 419 412i captive insurance and section 79 scams and answer the following:
    • What is the IRS’s position with respect to the Sea Nine VEBA, 419 captive insurance and section 79 scams?
    • What will be the likely result of my audit?
    • What if I don't agree with my audit results?
    • What are other participants doing with respect to the audits?
    • Will the IRS impose interest and penalties?
    • What is a “listed transaction”?
    • What is Form 8886, and what are the penalties for failing to file Form 8886?
    • Will I be responsible even if I relied on my tax advisor?
    • What recourse do I have against those that promoted and sold the Sea Nine VEBA?
    The information provided herein is not intended as legal, accounting, financial or any other type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.
    ABOUT THE AUTHOR: Lance Wallach
    Lance Wallach, CLU, ChFC, CIMC, speaks and writes extensively about financial planning, retirement plans, and tax reduction strategies. He is an American Institute of CPA’s course developer and instructor and has authored numerous best selling books about abusive tax shelters, IRS crackdowns and attacks and other tax matters. He speaks at more than 20 national conventions annually and writes for more than 50 national publications.
    Copyright Lance Wallach, CLU, CHFC
    More information about Lance Wallach, CLU, CHFC
    Disclaimer: While every effort has been made to ensure the accuracy of this publication, it is not intended to provide legal advice as individual situations will differ and should be discussed with an expert and/or lawyer. For specific technical or legal advice on the information provided and related topics, please contact the author.
    Disclaimer: While every effort has been made to ensure the accuracy of this publication, it is not intended to provide legal advice as individual situations will differ and should be discussed with an expert and/or lawyer. For specific technical or legal advice on the information provided and related topics, please contact the author.
    About the Author
    ABOUT THE AUTHOR: Lance Wallach
    Lance Wallach, CLU, ChFC, CIMC, speaks and writes extensively about financial planning, retirement plans, and tax reduction strategies. He is an American Institute of CPA’s course developer and instructor and has authored numerous best selling books about abusive tax shelters, IRS crackdowns and attacks and other tax matters. He speaks at more than 20 national conventions annually and writes for more than 50 national publications.

    ReplyDelete
  32. Lance Wallach helps with 419 problems. 412i 419 abusive tax shelters IRS audits, lawsuits, Lance Wallach will help www.vebaplan.com
    419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this.
    Dennis Cunning Steve Toth Randall Smith Paul Kaplan Herb Green Casey Hermansen
    Larry Bell Scott Ridge Judy Carsrud Jeffrey Glasberg Herb McDowel
    Greg Roper Joseph Donnelly
    Norm Bevan Michael Sonnenberg
    r Anthony Fakouri
    Steve Burgess
    Robin Weingast
    IRS audits 419 412i captive insurance and section 79 plans. Lance Wallach will help you.

    IRS audits section 79 419 412i plans. www.lancewallach.com for help
    , IRS raids, Niche, Robin Weingast, Lance Wallach helps, Sadi trust, grist Mill trust, nova 419 welfare benefit plan problems and how Lance Wallach helps.www.vebaplan.com for more help. Sea Nine VEBA, 419, 412i, IRS audits,Sea Nine VEBA, are all audited by the IRS and people in them probably need help.
    Sea Nine VEBA, 419,412i are all IRS audit targets. Lance Wallach can help, www.tazaudit419.com
    419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this. Author to write about these problems.
    Dennis Cunning Steve Toth Randall Smith Paul Kaplan Herb Green Casey Hermansen
    Larry Bell Scott Ridge Judy Carsrud Jeffrey Glasberg Herb McDowel
    Greg Roper Joseph Donnelly
    Norm Bevan Michael Sonnenberg
    Anthony Fakouri
    Steve Burgess
    Robin Weingast
    " Lance Wallach will help fix the problems that people have that are or were in the plans.
    "Professional Benefits Trust" PBI

    "Sea Nine Veba"
    Bisys
    The "Beta Plan"
    The "Millennium Plan"

    Niche
    The "Ridge Plan"


    The "Compass Welfare Benefit Plan"
    "Section 79 Plans"
    "Captive Insurance"
    and other similar "412i retirement plans" and "419 welfare benefit plans

    Lance Wallach, www.taxaudit419.com will help you with these problems and more like section 79, captive insurance lawsuits and IRS audits. People in the section 79 plans 419 welfare benefit plans captive insurance and 412i pension plans are getting audited by the IRS and then they sue. Google Lance Wallach for help with this. If you need help Lance Wallach as an expert witness has never lost a case. You need help NOW. Google lance wallach or www.vebaplan.com for 419 412i captive insurance or section 79 audits lawsuits get your money back etc.

    Customers of James Cunningham d/b/a Cunningham Financial or CFG Consulting LLC? We want to speak with you!
    IRS audits and lawsuits result from 419 412i captive insurance and section 79 plans. As an expert witness Lance Wallach has never lost a case

    ReplyDelete
  33. Abusive Tax Shelters
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.

    Tuesday, November 27, 2012

    419 and 412 Plan Fraud

    You think you know what you are getting when you buy an insurance plan, but what do you do when you find out that your plan does not work they way you thought? If you have been misled by your insurance broker, you may have been the victim of fraud. We protect the rights of the victims of 419 and 412 plan fraud.
    Have you purchased an IRC 419 Employee Welfare Benefit Plan after being told the contributions were fully deductible from federal and state income taxes, only to find out that this was not the case?
    Did you purchase a trust you may not have needed, funded with substantial amounts of life insurance because you were told you could build up cash value tax-free and then have use of the funds tax-free?
    If you have been misled about information regarding your employee welfare benefits, you may have been the victim of 419 and 412 plan fraud.
    When consumers are misled and given false information by insurance brokers, they have the right to sue the fraudulent agents and insurance company that sold the plan.


    LanceWallach, CLU, ChFC, CIMC, speaks and writes extensively about financial planning, retirement plans, and tax reduction strategies. He is an American Institute of CPA’s course developer and instructor and has authored numerous best selling books about abusive tax shelters, IRS crackdowns and attacks and other tax matters. He speaks at more than 20 national conventions annually and writes for more than 50 national publications. For more information and additional articles on these subjects, visit www.vebaplan.com, www.taxlibrary.us, lawyer4audits.com or call 516-938-5007.

    The information provided herein is not intended as legal, accounting, financial or any other type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.

    ReplyDelete
  34. Captive Insurance & 419 Plans Litigation
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,Captive Insurance,Captive Insurance Lawsuits,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,

    FRIDAY, MAY 23, 2014
    Home
    Home
    Posted by Lance Wallach at 12:10 PM No comments:
    Newer Posts Older Posts Home
    Subscribe to: Posts (Atom)
    LANCE WALLACH IS A NATIONALLY RECOGNIZED EXPERT, AUTHOR, AICPA INSTRUCTOR AND SPEAKER.
    "Protecting Clients from Fraud, Incompetence, and Scams" published by John Wiley & Sons
    Mr. Wallach is the National Society of Accountant's Speaker of the Year and the author of numerous professional books, including:
    "Avoiding Circular 230 Malpractice Traps and Common Abusive Small Businesss Hot Spots" by the AICPA - author/moderator Lance Wallach
    The AICPA's "The team approach to Tax, Financial and Estate Planning."
    "The CPA's Guide to Life Insurance" by Bisk CPEasy
    "Wealth Preservation Planning" by the National Society of Accountants
    "The CPA's Guide to Federal and Estate Gift Taxation" published by Bisk
    GET OUR FREE $200K REPORT
    Get our Free $200K report
    Get our Free $200K report
    IRS $200K PENALTY VIDEO - CLICK PICTURE TO PLAY

    ReplyDelete
  35. Lawyers, Law Firms, Legal InformationFind a Lawyer

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    How Hartford Life and Other Insurance Companies Tricked their Agents and Got People in Trouble with the IRS
    By Lance Wallach, CLU, CHFC

    Firm's Profile & ArticlesFirm's Profile & Articles

    Find a Law Firm:
    ► Need a Lawyer? Let Us Help You

    Agents from Hartford and other insurance companies were shown ways to sell large life insurance policies. This “Welfare Benefit Trust 419 plan or 412i plan should be shown to their profitable small business owners as a cure for paying too much taxes.

    A Welfare Benefit Trust 419 plan essentially works like this:

    ReplyDelete
  36. Lawyers, Law Firms, Legal InformationFind a Lawyer

    List Your Firm
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    Captive Insurance Arrangements Are on the IRS Radar
    By Lance Wallach, CLU, CHFC

    Firm's Profile & ArticlesFirm's Profile & Articles

    Find a Law Firm:
    ► Need a Lawyer? Let Us Help You

    Internal Revenue Service scrutiny of captive insurance arrangements is increasing, and much of it is aimed at small captives utilizing the 831(b) tax election, say many in the captive industry.

    Large or small, captives must be formed for the right reasons, their premiums must be appropriate and their business plans must involve genuine insurance, captive experts say.

    But some “minicaptive” or “microcaptive” formations under Section 831 (b) of the Internal Revenue Code lack a genuine insurance purpose and instead provide tax shelters for their owners, experts say. IRS scrutiny drawn by improper use of captives threatens to cast a bad light on the entire captive industry, many fear.

    “Supposedly, the word is out of the general counsel's office that the IRS in the last year or so has taken an increased interest in captives,” said Jay Adkisson, a partner at Riser Adkisson L.L.P. in Newport Beach, Calif., and chairman of the American Bar Association's committee on captive insurance. “There are more cases against captives than ever before.”

    Some people “have their own motivations for getting clients into captives that don't necessarily involve risk management, let’s just call them what they are: They're tax shelters.

    If the IRS wanted to make a lot of money, they could go out and audit every one of the 831(b) captives that's doing terrorism coverage,” he said. Terrorism coverage “tends to be a hallmark of the tax shelter captives. They're coming up with these terrorism covers and the pricing bears utterly no relationship to any kind of reality.”

    Under Section 831(b), property/casualty captives earning less than $1.2 million in annual premium may elect to pay U.S. taxes only on their investment income.

    The provision, part of the Tax Reform Act of 1986, was meant to encourage formation of insurance companies and simplify business for small companies. The rapid growth of small captives taking advantage of the 831(b) election has driven similar rapid growth of several newer captive domiciles such as Utah, Montana and Kentucky as it has added to many captive managers' rosters of captive clients.

    If you set up a captive we suggest you file under IRS 6707A to reduce fines if you do get audited.

    ABOUT THE AUTHOR: Lance Wallach
    Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, abusive tax shelters, financial, international tax, and estate planning. He writes about 412(i), 419, Section79, FBAR and captive insurance plans. He speaks at more than ten conventions annually, writes for more than 50 publications, is quoted regularly in the press and has been featured on television and radio financial talk shows.

    Copyright Lance Wallach, CLU, CHFC
    More information about Lance Wallach, CLU, CHFC

    Disclaimer: While every effort has been made to ensure the accuracy of this publication, it is not intended to provide legal advice as individual situations will differ and should be discussed with an expert and/or lawyer. For specific technical or legal advice on the information provided and related topics, please contact the author

    ReplyDelete
    Replies
    1. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205

      Delete
  37. Journal of Accountancy Large Logo
    Home > September 2008 > Abusive Insurance and Retirement Plans
    ShareThis | Print Article Print
    TAX / EMPLOYEE BENEFITS
    Abusive Insurance and Retirement Plans

    Single–employer section 419 welfare benefit plans are the latest incarnation in insurance deductions the IRS deems abusive
    BY LANCE WALLACH
    SEPTEMBER 2008
    EXECUTIVE SUMMARY

    Some of the listed transactions CPA tax practitioners are most likely to encounter are employee benefit insurance plans that the IRS has deemed abusive. Many of these plans have been sold by promoters in conjunction with life insurance companies.

    As long ago as 1984, with the addition of IRC §§ 419 and 419A, Congress and the IRS took aim at unduly accelerated deductions and other perceived abuses. More recently, with guidance and a ruling issued in fall 2007, the Service declared as abusive certain trust arrangements involving cash-value life insurance and providing post-retirement medical and life insurance benefits.

    The new "more likely than not" penalty standard for tax preparers under IRC § 6694 raises the stakes for CPAs whose clients may have maintained or participated in such a plan. Failure to disclose a listed transaction carries particularly severe potential penalties.

    Lance Wallach, CLU, ChFC, CIMC, is the author of the AICPA’s The Team Approach to Tax, Financial and Estate Planning. He can be reached at lawallach@aol.com or on the Web at, www.vebaplan.com or 516-938-5007. The information in this article is not intended as accounting, legal, financial or any other type of advice for any specific individual or other entity. You should consult an appropriate professional for such advice.



    Many of the listed transactions that can get your clients into trouble with the IRS are exotic shelters that relatively few practitioners ever encounter. When was the last time you saw someone file a return as a Guamanian trust (Notice 2000-61)? On the other hand, a few listed transactions concern relatively common employee benefit plans the IRS has deemed tax-avoidance schemes or otherwise abusive. Perhaps some of the most likely to crop up, especially in small business returns, are arrangements purporting to allow deductibility of premiums paid for life insurance under a welf

    ReplyDelete
  38. Section 79 Plans
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance reportable or listed transactions by the IRS,Section 79, Section 79 Lawsuits,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.Benistar,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,

    Thursday, December 19, 2013

    419, 412i, and Section 79 Investment Plans
    419, 412i, and Section 79 Investment Plans

    If your CPA, financial advisor, or insurance agent introduced you to one of these plans and now the IRS is after you, contact us immediately. You may be a victim of insurance fraud. We want to help protect your business and your hard-earned income.
    Likewise, if you currently participate in one of these plans, and are worried about whether the IRS will penalize you, give us a call. We can help you make sure your plan is legit, and that no one tried to trick you in order to get a huge commission.
    How your CPA, financial advisor, or insurance agent may be responsible for your audit:
    Improper filing of form 8886
    Misrepresentation of the tax code
    Misunderstanding of the tax code
    Failure to explain certain details of the plan
    Bad math/calculations
    Dishonesty
    Despite these mistakes or misleadings by your CPA, financial advisor, or insurance agent, the IRS will come after you, the small business owner, if something is amiss. Where is the justice? These advisors should be held responsible for the damages you are incurring. We want to help you fight the people who took advantage of you and make them accountable for their actions.

    ReplyDelete
    Replies
    1. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205

      Delete
  39. Participated in a Sea Nine VEBA plan_Contact Lance Wallach

    Wednesday, January 8, 2014

    Financial Devastation for Clients in 419 Plans
    Some of you may remember the bad old days of using 419 welfare benefit plans to help business owners (and doctors specifically) take massive deductions where the money ultimately went into cash value life insurance. These plans were sold as a benefit plans, but they were really discriminatory deferred compensation plans in sheep’s clothing. For a while, there was a legitimate use of 419 plans with life insurance, but it didn’t take long for the industry to come crashing down due to the abuses that took place.

    Unfortunately, for many, the fallout from those who used 419 plans is still happening today. In the Jerald W. White v. Commissioner (April 2012) case, a doctor who took large deductions for 419 plan contributions lost his audit and ended up not only paying back taxes but also interest and penalties.

    What’s interesting about this case besides the reminder that bad tax structures can be financially devastating for clients is the discussion about back taxes and penalties. The defendant tried to get out of back taxes and penalties by stating that the deduction was based on reasonable cause and reliance on substantial authority for such deductions. The court pointed out that at no time did the doctor seek out independent counsel on the authority, and that the doctor relied on the promises of interested parties even though it was clear that the promises seemed too good to be true.
    As an expert witness Lance Wallachs side has never lost a case. He has won for both plaintiffs and defendants, but not on the same case, that is a joke. That is not a joke to most people that went into the bad 419 or 412i plans. They were audited, and then many tried to sue. When they used a lawyer who was learning on the job they would lose the lawsuit.

    Posted by Lance Wallach at 11:26

    ReplyDelete
  40. The Offices of Lance Wallach * 516-938-5007 * wallachinc@gmail.com
    Nationwide Assistance “abusive tax shelter help” "tax letter" "irs letter" "irs letters" "irs determination letter" 419e 412i 6707a "form 8886" "listed transactions" "abusive tax shelter assistance" "irs penalty abatement" "expert witness irs" veba "expert witness services" "expert witness irs help" "pension audit" "Grist Mill Trust" Benistar "SADI Trust" "Beta 419" "Millennium Plan" Bisys "Creative Services Group" "Sterling Benefit Plan" "Compass 419" Niche "Sea Nine Veba" 419 412i 419e "expert witness insurance" "welfare benefit plans" "419 plan help" "expert witness irs" “abusive tax shelter help” “irs appeal” “tax resolution services” “insurance expert witnesses” “pension plan audit” “tax preparer penalties” “tax audit defense” “business tax audit” “tax penalty abatement” “irs tax problems” “circular 230” “retirement tax shelters” “health insurance fraud” “employer insurance fraud” “irs trouble” “unfiled tax returns” “unfiled taxes” 419 412i "listed transactions" "form 8886" 6707A "tax shelters" "IRS audi

    ReplyDelete
    Replies
    1. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205

      Delete
  41. As an expert witness Lance Wallach side has never lost a case

    FRIDAY, NOVEMBER 22, 2013
    Could We Have This Debate Before It Is Too Late? Lance Wallach, expert witness.
    Is the use of fully insured group health insurance products as stop-loss coverage for group health plans going to remain a viable solution?

    The obvious question that follows is: Are State Departments of Insurance Compelled by the Affordable Care Act (ACA) To Limit Fully Insured Health Products to Minimum Essential Benefits?

    Short answer is a resounding No. This is an intriguing question which is being hashed out across our land and I am sad to say that most DOIs are getting it wrong. Section 1301, Paragraph (b), 1, A, the ACA is very clear in its definition of a health plan:

    1) Health Plans—

    (A) In General.—the term ‘‘health plan’’ means health insurance coverage and a group health plan.

    Did that come through? “And a group health plan”.

    One of the things that came out of the ACA, which I only hear complaining about, is the Medical Loss Ratio (MLR) mandate; 80% of small group (99 and under) and 85% of large group premium dollars must go to fund patient care. This puts fully insured products in the strange position of being underpriced as a stop-loss product.

    Fully insured as a stop-loss is underpriced for a couple reasons.

    1. Traditional stop-loss runs at a Medical Loss Ratio somewhere around 60%. The difference of 20% - 25% should jump off the page when you think about this.

    2. The risk. Specific deductibles of $20K - $50K or more turn into standard deductibles of $5 - $25K. The biggest thing about this is that we are working with “standard” deductibles which limit deductible count to one or two per family and I am not speaking of aggregate v. embedded, I am truly speaking of one or two deductibles per family.

    Just when this is dawning on the market and employers are finding ways to offer truly affordable benefits to their people, some state departments of insurance have disallowed High Deductible Health Plan (HDHPs) from existing legally in their state. Instead they might consider requiring health plans to comply with the ACA and keep offerings as diverse as possible to allow the market to function and keep prices down.

    Let’s do a quick mental exercise to illustrate my point. Track with me on premium costs for a moment: Premiums rise exponentially as deductibles go down. If the desired effects are lower costs, then it makes

    ReplyDelete
  42. ost a Comment On: Captive Insurance & 419 Plans Litigation

    "Captive Insurance Companies and Risk Retention Groups"
    3 Comments - Show Original Post
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    1 – 3 of 3
    Blogger Lance Wallach said...
    Captive Insurance & 419 Plans Litigation
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,Captive Insurance,Captive Insurance Lawsuits,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,

    FRIDAY, APRIL 18, 2014
    Posted by Lance Wallach at 8:01 AM No comments:
    Labels: 412i, 412i Benefit Plan, 412i Benefit Plans, 419 Plan, Abusive Insurance Products, Abusive Retirement Plans 412i, abusive transactions, appraisal services
    Older Posts Home
    Subscribe to: Posts (Atom)
    LANCE WALLACH IS A NATIONALLY RECOGNIZED EXPERT, AUTHOR, AICPA INSTRUCTOR AND SPEAKER.
    "Protecting Clients from Fraud, Incompetence, and Scams" published by John Wiley & Sons
    Mr. Wallach is the National Society of Accountant's Speaker of the Year and the author of numerous professional books, including:
    "Avoiding Circular 230 Malpractice Traps and Common Abusive Small Businesss Hot Spots" by the AICPA - author/moderator Lance Wallach
    The AICPA's "The team approach to Tax, Financial and Estate Planning."
    "The CPA's Guide to Life Insurance" by Bisk CPEasy

    April 21, 2014 at 4:08 AM
    Blogger Lance Wallach said...
    Captive Insurance & 419 Plans Litigation
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,Captive Insurance,Captive Insurance Lawsuits,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,

    FRIDAY, APRIL 18, 2014
    Posted by Lance Wallach at 8:01 AM No comments:
    Labels: 412i, 412i Benefit Plan, 412i Benefit Plans, 419 Plan, Abusive Insurance Products, Abusive Retirement Plans 412i, abusive transactions, appraisal services
    Older Posts Home
    Subscribe to: Posts (Atom)
    LANCE WALLACH IS A NATIONALLY RECOGNIZED EXPERT, AUTHOR, AICPA INSTRUCTOR AND SPEAKER.
    "Protecting Clients from Fraud, Incompetence, and Scams" published by John Wiley & Sons
    Mr. Wallach is the National Society of Accountant's Speaker of the Year and the author of numerous professional books, including:

    ReplyDelete
  43. 412i 419 sect 79 lawsuits audits www.lancewallach.com for help (plainview)


    © craigslist - Map data © OpenStreetMap
    (google map) (yahoo map)

    compensation: no pay
    Lance Wallach helps with 419 problems. 412i 419 abusive tax shelters IRS audits, lawsuits, Lance Wallach will help www.vebaplan.com
    419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this.
    Dennis Cunning Steve Toth Randall Smith Paul Kaplan Herb Green Casey Hermansen
    Larry Bell Scott Ridge Judy Carsrud Jeffrey Glasberg Herb McDowel
    Greg Roper Joseph Donnelly
    Norm Bevan Michael Sonnenberg
    r Anthony Fakouri
    Steve Burgess
    Robin Weingast
    IRS audits 419 412i captive insurance and section 79 plans. Lance Wallach will help you.

    IRS audits section 79 419 412i plans. www.lancewallach.com for help
    Benistar, IRS raids, Niche, Robin Weingast, Lance Wallach helps, Sadi trust, grist Mill trust, nova 419 welfare benefit plan problems and how Lance Wallach helps.www.vebaplan.com for more help. Sea Nine VEBA, 419, 412i, IRS audits,Sea Nine VEBA, are all audited by the IRS and people in them probably need help.
    Sea Nine VEBA, 419,412i are all IRS audit targets. Lance Wallach can help, www.tazaudit419.com
    419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this. Author to write about these problems.
    Dennis Cunning Steve Toth Randall Smith Paul Kaplan Herb Green Casey Hermansen
    Larry Bell Scott Ridge Judy Carsrud Jeffrey Glasberg Herb McDowel
    Greg Roper Joseph Donnelly
    Norm Bevan Michael Sonnenberg
    Anthony Fakouri
    Steve Burgess
    Robin Weingast
    " Lance Wallach will help fix the problems that people have that are or were in the plans.
    "Professional Benefits Trust" PBI

    "Sea Nine Veba"
    Bisys
    The "Beta Plan"
    The "Millennium Plan"

    Niche
    The "Ridge Plan"


    The "Compass Welfare Benefit Plan"
    "Section 79 Plans"
    "Captive Insurance"
    and other similar "412i retirement plans" and "419 welfare benefit plans

    Lance Wallach, www.taxaudit419.com will help you with these problems and more like section 79, captive insurance lawsuits and IRS audits. People in the section 79 plans 419 welfare benefit plans captive insurance and 412i pension plans are getting audited by the IRS and then they sue. Google Lance Wallach for help with this. If you need help Lance Wallach as an expert witness has never lost a case. You need help NOW.

    Customers of James Cunningham d/b/a Cunningham Financial or CFG Consulting LLC? We want to speak with you!
    IRS audits and lawsuits result from 419 412i captive insurance and section 79 plans. As an expert witness Lance Wallach has never lost a case.

    ReplyDelete
    Replies
    1. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205

      Delete
  44. Captive Insurance Plans: The Dangers of Being “Listed”
    19 October 2011
    Guest post by Lance Wallach

    Taxpayers who previously adopted 419, 412i, captive insurance or Section 79 plans are in big trouble. In recent years, the IRS has identified many of these arrangements as abusive devices to funnel tax deductible dollars to shareholders and classified these arrangements as “listed transactions.”

    These plans were sold by insurance agents, financial planners, accountants and attorneys seeking large life insurance commissions. In general, taxpayers who engage in a “listed transaction” must report such transaction to the IRS on Form 8886 every year that they “participate” in the transaction, and you do not necessarily have to make a contribution or claim a tax deduction to participate. Section 6707A of the Code imposes severe penalties ($200,000 for a business and $100,000 for an individual) for failure to file Form 8886 with respect to a listed transaction.

    But you are also in trouble if you file incorrectly.

    I have received numerous phone calls from business owners who filed and still got fined. Not only do you have to file Form 8886, but it has to be prepared correctly. I only know of two people in the United States who have filed these forms properly for clients. They tell me that was after hundreds of hours of research and over fifty phones calls to various IRS personnel.

    The filing instructions for Form 8886 presume a timely filing. Most people file late and follow the directions for currently preparing the forms. Then the IRS fines the business owner. The tax court does not have jurisdiction to abate or lower such penalties imposed by the IRS. Many business owners adopted 412i, 419, captive insurance and Section 79 plans based upon representations provided by insurance professionals that the plans were legitimate plans and were not informed that they were engaging in a listed transaction. Upon audit, these taxpayers were shocked when the IRS asserted penalties under Section 6707A of the Code in the hundreds of thousands of dollars. Numerous complaints from these taxpayers caused Congress to impose a moratorium on assessment of Section 6707A penalties.

    The moratorium on IRS fines expired on June 1, 2010. The IRS immediately started sending out notices proposing the imposition of Section 6707A penalties along with requests for lengthy extensions of the Statute of Limitations for the purpose of assessing tax. Many of these taxpa
    Today.

    ReplyDelete
    Replies
    1. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205

      Delete
  45. Captive Insurance & 419 Plans Litigation
    412i, 419e plans, litigation, IRS Audit Experts. abusive insurance plans reportable or listed transactions,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,Captive Insurance,Captive Insurance Lawsuits,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,

    WEDNESDAY, MAY 8, 2013
    IRS Wants You to Know About Schemes, Scams and Cons:


    Lance Wallach

    If it sounds too good to be true, it probably is!" Seek professional advice from the IRS or a Tax Professional before you subscribe to any scheme that offers exemption from your obligation as a United States Citizen to pay taxes. Buying into a tax evasion scheme can be very costly.
    Department of Justice Press Releases on Civil and Criminal Actions Taken as a Result of IRS Enforcement Activities
    The Department of Justice issues press releases on IRS enforcement activities.
    Tax Scams: How to Recognize and Avoid Them
    To help the public recognize and avoid abusive tax schemes, the IRS offers an abundance of educational materials. Participating in an illegal scheme to avoid paying taxes can result in imprisonment and fines, as well as the repayment of taxes owed with penalties and interest. Education is the best way to avoid the pitfalls of these “too good to be true” tax scams.
    Tax Scams/Consumer Alerts
    Don't fall victim to tax scams. The IRS issues News Releases on some of the common scams, including the annual Dirty Dozen news release.
    Special Advice for Law Enforcement on Avoiding Tax Preparer Scams
    Enforcing the Laws and Paying Taxes: Is there a Connection?
    This is one of many outreach articles the IRS prepares to help educate the public about tax scams.
    Examples of Fraud Investigations
    In addition to the Tax Fraud Alerts page, Criminal Investigation (CI) wants you to know about other areas of fraud in which individuals have been criminally prosecuted.

    ReplyDelete
    Replies
    1. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205

      Delete
  46. Large IRS Fines Continue For 419, 412i, Captive Insurance and Section79 Plans



    Guest Post by Lance Wallach

    Taxpayers must report certain transactions to the IRS under Section 6707A of the Tax Code, which was enacted in 2004 to help detect, deter, and shut down abusive tax shelter activities. For example, reportable transactions may include being in a 419,412i, or other insurance plan sold by insurance agents for tax deduction purposes. Other abusive transactions could include captive insurance and section 79 plans, which are usually sold by insurance agents for tax deductions. Taxpayers must disclose their participation in these and other transactions by filing a Reportable Transactions Disclosure Statement (Form 8886) with their income tax returns. People that sell these plans are called material advisors and must also file 8918 forms properly. Failure to report the transactions could result in very large penalties. Accountants who sign tax returns, which have these deductions, can also be called material advisors and should also file forms 8918 properly.

    The IRS has fined hundreds of taxpayers who did file under 6707A. They said that they did not fill out the forms properly, or did not file correctly. The plan administrator of a 412i advised over 200 of his clients how to file. They were then all fined by the IRS for filling out the forms wrong. The fines averaged about $500,000 per taxpayer.

    A report by the Treasury Inspector General for Tax Administration (TI

    ReplyDelete
  47. The Home of Business Appraisals
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    BV Company Blog
    Better Business Valuation: separating teachers & students


    ‘We wrote the books on how to value a business that other valuation companies live by! If you want to sleep soundly at night, don’t go to the students for your financial solutions, seek the teachers!’

    -Lance Wallach



    business valuations
    The Business of Business
    Valuations…
    We cater to US-based, privately-held businesses that need an independent valuation, or third-party company appraisal services. Company valuation resources are available to you, courtesy of the age of information. Anybody could value their own business. We’re trained financial analysts and lawyers who’ve studied economic trends with the best of them. Our fair service, pricing, attention to detail, expert staff, valuation methods, and customer-focused approach make our business valuation services ultimately worth your time.

    Nationwide Business
    Valuations
    NSAS speaker of the year and AICPA faculty Lance Wallach is a valuations analyst. He and his certified, expert team of CPA valuation consultants service private businesses seeking appraisals or litigation support. Their valuation formula caters to nationwide business sales or purchases with revenues of $1MM to 55MM, and small business revenues from $500k to $5MM. Lance Wallach’s and his CPA consultants’ confidence is predicated on their extensive financial analyst experience in New York and the U.S. Nationwide.

    Business Appraisal Services: Our
    Specialties
    You can benefit from our valuation services if you are: a firm facing Merger & Acquisition decisions; if you are an owner who needs CFO business advisory for team-members; if you are an attorney, business owner, or accountant who needs an expert to perform forensic valuation services, like fraud & litigation support. Other services include valuation buy/sell agreements, partnership dissolution, marital dissolution of business assets, and estate, gift or tax matters.


    Your Next Step: Company Valuation Free
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    If you have questions and would like a free consultation, please call 516-938-5007 to speak with an expert business valuator

    You can also email to wallachinc@gmail.com
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    ReplyDelete
  48. on








    Copyright (C) 2010 - Lance Wallach

    Our team of experienced consulting "tax attorneys", CPAs, and "insurance experts" specializing in 412i" and "419 "IRS
    audits" that resulted from plans you sold to your clients, mainly "419 plans", "412i plans", "captive insurance" plans
    and "Section 79" plans as well as other similar "employee benefit plans" or "welfare benefit plans" that the IRS is
    targeting as "abusive tax shelters".

    Our firm has been successful in "defending life insurance agents" and "material advisors" who have participated in
    the sale of these "benefit plans".

    If you signed a return or participated in the sale of these "welfare benefit plans", you are probably a "material
    advisor" and subject to huge "IRS penalties and interest". No "Form 8886" or "Form 8918" that we have reviewed for
    new clients has been properly prepared, which leaves the "material advisor" subject to the $200,000 "IRS penalty".

    We fight for our clients to defend against the $200,000 IRS "6707A penalty" by providing "expert witness
    testimony". Lance's side has never lost a case!

    ReplyDelete
    Replies
    1. The Truth About Section 79 Permanent Insurance Plans


      Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

      Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

      So, here’s the truth about Section 79 Permanent Insurance Plans:
      • This is a legal insurance product, covered in the IRS Code number 1.79.
      • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
      • This is not a new code. The IRC 1.79 has been in the code since 1953.
      • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
      • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
      • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

      For REAL information on Section 79 please contact Business Planning Group at BusinessPLanningGroup.com or call us directly at: (888) 545-2205

      Delete

  49. The complexity of life insurance puts many litigators at a disadvantage when disputes reach the stage of legal action. In addition, if policies are part of a retirement plan or other tax-favored entity, special rules apply. Even the methods of paying for life insurance—especially split-dollar and outside premium financing—affect an outcome. Tax implications are another factor.

    Lance Wallach is one of few professionals who know how the pieces work both alone and with estate and financial planning. In many situations, what the client bought or the way that they bought it was inappropriate. In other cases the right product was sold in the right way but the purchaser is unhappy. Richard has the forensic ability to uncover what has taken place.

    Working for both plaintiffs and defendants, depending on the merits of the case, Lance advises, opines, and testifies based upon the facts, his knowledge and experience. This makes him a very powerful and credible witness.

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  50. The Office of Lance Wallach
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    "America's leading tax representation firm."(TM)

    Serving clients
    nationwide

    Call us today:

    516-938-5007

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    Every one of our
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    Lance Wallach
    Managing Director




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  51. Get the latest industry news SubscribeNewsletter

    When the IRS audits a participant in one of these plans, the tax deductions are lost. There is also the interest and large penalties to consider. The business owner can also be facing a $200,000-a-year fine if he did not properly file Form 8886. Most of these forms have been filled out improperly. In my talks with the IRS, I was told that the IRS considers not filling out Form 8886 properly almost the same as not filing at all.

    412(i) retirement plans

    The IRS has been auditing participants in these types of retirement plans. While there is generally nothing wrong with many of the newer plans, the IRS considered most of the older abusive plans. Forms 8918 and 8886 are also required for abusive 412(i) plans.

    I have been an expert witness in a lot of these 419 and 412(i) lawsuits and I have not lost one of them. If you sold one or more of these plans, get someone who really knows what they are doing to help you immediately. Many advisors will take your money and claim to be able to help you. Make sure they have experience helping agents that have sold these types of plans. Don't let them learn on the job, with your career and money at stake.

    Do not wait for IRS to come and get you, or for your client to sue you. Time is of the essence. Most insurance professionals need help to correct their improperly completed Form 8918 or to fill it out properly in the first place. If you have not previously filled out the form it is late, and therefore you should immediately seek assistance. There are plenty of legitimate tax reduction insurance plans out there. Just make sure that you know the history of the people with whom you conduct business.

    Remember, if something looks too good to be true, it usually is. Be careful.


    Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, abusive tax shelters, financial, international tax, and estate planning. He writes about 412(i), 419, Section79, FBAR and captive insurance plans. He speaks at more than ten conventions annually, writes for more than 50 publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Public Radio’s “All Things Considered” and others. Lance has written numerous books including “Protecting Clients from Fraud, Incompetence and Scams,” published by John Wiley and Sons, Bisk Education’s “CPA’s Guide to Life Insurance and Federal Estate and Gift Taxation,” as well as the AICPA best-selling books, including “Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots.” He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmai­l.com or visit www.taxadvisore­xpert.com.
    The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.
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  52. It Works
    Posted on April 17, 2012

    LANCE WALLACH

    PARTIES:
    Typically, these transactions will include an Insurance company, accountant, tax attorney, and a promoter (someone with an insurance background, perhaps an actuary, who knows how to structure the policy itself). These groups will use insurance brokerages and sub-agents (licensed in the various states) to sell the policies themselves.
    INSURANCE COMPANIES
    AMERICAN GENERAL LIFE INSURANCE COMPANY® INDIANAPOLIS LIFE INSURANCE COMPANY®
    HARTFORD LIFE AND ANNUITY INSURANCE COMPANY® PACIFIC LIFE INSURANCE COMPANY®
    BANKERS LIFE and OTHERS®?
    4121iHOW THESE PLANS WORK:
    In the late 1990’s, the individuals and groups above devised a scheme to sell abusive tax shelters under the auspices of Section 412(i) of the tax code. A 412(i) is a defined benefit pension plan. It provides specific retirement benefits to participants once they reach retirement and must contain assets sufficient to pay those benefits. A 412(i) plan differs from other defined benefit pension plans in that it must be funded exclusively by the purchase of individual life insurance products. To create a 412(i) plan, there must be a trust to hold the assets. The employer funds the plan by making cash contributions to the trust, and the Code allows the employer to take a tax deduction in the amount of the contributions, i.e. the entire amount.
    The trust uses the contributed funds to purchase some combination of life insurance products (insurance or annuities) for the plan. As the plan participants retire, the trust will usually sell the policies for their present cash value and purchase annuities with the proceeds. The revenue stream from the annuities pays the specified retirement benefit to plan participants.
    These defendants (with the aid and knowledge of the insurance companies) used the traditional structure and sold life insurance policies with excessively high premiums. The trust then uses the large cash contributions to pay high insurance premiums and the employer takes a deduction for the sum of those large contributions. As you might expect, these policies were designed with excessively high fees or “loads” which provided exorbitant commissions to the insurance companies and the agents who sold the products.

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